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Share plan? Another return to do by 6 July

26 February 2019

At this busy time of year for HR and payroll departments, it could be easy to focus on gender pay reporting, then P60s and P11Ds and put share plan year end returns to one side - but that could prove expensive.

All companies with any type of employee share plan or arrangement - collectively Employment Related Securities (ERS) - have been required to register them. Once registered, annual online returns are required for every ERS plan or arrangement - even if they are nil returns.

Informal plans, gifts, loan notes and share transfers

You don’t have to have a tax-advantaged share plan or highly engineered arrangement to trigger a filing obligation: virtually any employee or director share or security transaction can trigger the need to register a ‘plan’ and submit a return. If you are not sure whether or not a transaction must be reported, take our self-test.


If a return for an ERS plan or arrangement is not submitted by the 6 July deadline a fixed £100 penalty will be charged. Further £300 penalties will be charged on 6 October, 6 January and 6 April if the return is still not filed. Daily penalties can then be applied. Penalties can mount up and failure to complete returns may also impact on HMRC’s risk rating for the company and could subsequently result in an unwanted visit from HMRC.

Worse still, HMRC can deny valuable tax reliefs for certain tax-advantaged share plans if those set up during 2018/19 are not registered and self-certified by 6 July 2019.

Help and advice

BDO can assist with the registration process and provide a comprehensive filing guide for clients. If you operate large scale share plans with hundreds or thousands of lines of transactions to report, our diagnostic tool BDO Equity Reporter can ensure that annual returns are completed accurately and on time.

Employer Essentials Index

Share plans and incentives